Final Rule 2015: Here’s What You Need to Know

The summary of this year’s Final Rule is hot off the presses, which means that—among other things—we now know the details regarding PQRS 2015. For those who have been following the PQRS saga since the program first came into being in 2007, it should come as no surprise that Medicare has yet again upped the ante for compliance. Based on the fact sheet CMS provided, here’s the scoop on this year’s reporting requirements:

• Eligible professionals who fail to complete PQRS in 2015 will be subject to a 2% penalty, assessed as a payment adjustment in 2017.
• The number of individual measures on which eligible professionals must report to avoid the penalty has increased from three to as many as nine, "depending on whether the provider is using claims (6 measures available for 2015), or registry (9 required, or as many as apply to the provider)," according to this APTA press release. 
• As was the case in 2014, regardless of whether they report via claims or registry, providers must report on at least 50% of eligible Medicare patients.

With the number of measures you must report increasing to at least six, you might be wondering if you’ll have more measures to choose from this year. That remains to be seen; we won’t see the measures until we see the Final Rule in its entirety, which CMS has yet to publish to the Federal Register. Also up in the air: specifics regarding changes to the Group Practice Reporting Option (GPRO) criteria. According to this CMS fact sheet, the full Final Rule will be available on the Federal Register on November 13, 2014.

One more PQRS item of note: CMS delayed the inclusion of nonphysician eligible professionals—including physical therapists—in the value-based modifier (VM) program for another year. Although 2017 was the original implementation date for this change, it’s now set to go into effect in 2018. According to CMS, this delay will give nonphysician professionals adequate time to get acquainted with the VM program.  

Outside of PQRS, the CMS fact sheet provided details on the therapy cap:

• The 2015 caps for OT as well as PT and SLP combined are both increasing to $1,940 (up from $1,920 in 2014).
• The $3,700 manual medical review expires March 31, 2015, and Congress will need to act before then to address the expiration.

Lastly, the 2015 Medicare physician fee schedule includes “an aggregate increase in payment for physical therapy services of 1%,” according to CMS. But this increase depends on Congress stopping “implementation of a payment cut due to the flawed SGR formula by March 31.”